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A joint letter has been sent by 25 national, regional and local citizen organizations, representing hundreds of thousands of members, to the Environmental Protection Agency (EPA), Wisconsin Dept. of Natural Resources (DNR), and Governor Doyle’s office, calling for stronger measures in the Fox River and Green Bay PCB cleanup plan

The letter outlines citizen concerns with the partial upriver “Record of Decision,” released by the governments in January, and the downstream decision scheduled to be released in June.

“The first Record of Decision set dangerous precedents for the rest of the cleanup.  We urge our government leaders to take all steps possible to ensure that these deficiencies are not mirrored in the second Decision,” stated Dr. Jeffery Foran, toxicologist and president of Citizens for a Better Environment.

1. A Stronger Cleanup Level   The agencies’ own Remedial Investigation/ Feasibility Study/ Risk Assessment shows that the 1 ppm PCB sediment cleanup level chosen for the first Record of Decision is 90 times higher than PCB sediment concentrations that are fully protective of human health, and over 40 times higher than concentrations that are fully protective of wildlife. 
The Assessment also says that 0.25 ppm PCBs is the “most cost-effective PCB action level that meets protective thresholds.”  Our 25 citizen organizations call on the agencies to follow the recommendations provided in their own research and set a 0.25 ppm PCB action level for the Fox River and for those hot spots of the Bay that will be subject to removal of contaminated sediment. 

2. No Loopholes   The upstream Record of Decision contains a loophole that says that an “alternative remedy” can be used if it is as protective and costs less.  The emphasis throughout the rest of the document and in EPA’s summary is on “costs less.”   While our 25 citizen organizations agree that flexibility must be a component of any cleanup plan as extensive and complex as that proposed for the Fox River and Green Bay, such a broad loophole must be removed because it may result in less permanent clean up measures and undermines the public involvement process.  This “alternative remedy” section provides too much latitude to the seven paper companies who discharged the PCBs, leaving the door open for inappropriate technologies such as the use of capping as a remedy, with no public input.

3. “Natural Recovery” is Not Acceptable   The Record of Decision for the 20-mile stretch of the Fox River between Appleton and Little Rapids does not require removal of contaminated sediments; rather, it relies on “natural processes to break down, dilute, or bury PCBs” in this river stretch.  This assumption is in stark contrast with the conclusions and recommendations of the agencies’ own Feasibility Study, and with the vast scientific literature on PCBs, which conclude that significant natural degradation will not occur in the Fox River or Green Bay.  Therefore, “natural recovery” will not allow the stretch to meet remedial objectives for public health protection identified by the U.S. EPA and WDNR.   The 25 citizen organizations urge that this remedy not be used for the rest of the Fox River and Green Bay.

PCBs and other contaminants in the Fox River and Green Bay pose significant risks to human health and the environment.  Contamination has stigmatized this region of Wisconsin as unfit for the recreational and other non-industrial uses for which Wisconsin has become so well known.  These problems can be reduced or eliminated with a strong cleanup plan that removes PCB-contaminated sediments from all parts of the River and at least from the lower part of Green Bay.

The years of research and expertise culminating in the Remedial Investigation, Feasibility Study, and Risk Assessment provide the blueprint for the safest, most permanent course of action.

“Our 25 organizations call on the EPA and the WDNR to follow their own recommendations,” concluded Rebecca Katers, Executive Director of Clean Water Action Council, “and adopt a cleanup plan for the Fox River and Green Bay that addresses our concerns.”

Specifically, the final Record of Decision in June should:

• Acknowledge that flexibility is appropriate in any cleanup plan, but requires public scrutiny and input should changes be proposed, well before those changes are implemented; 

• Remove sediment contaminated with PCBs at levels above 0.25 ppm, a level that fully protects human health and the environment in a reasonable time frame; and

• Reject the concept of “monitored natural recovery,” which will not be effective in reducing PCB concentrations in any stretch of the Fox River or Green Bay;

To read or print-out the full letter, click here

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